This page explains when Commonwealth entities and companies must begin climate disclosure reporting, based on whether they fall under Stream 1 or Stream 2 and, for Stream 2, their Tranche.
Stream 1: Larger Commonwealth Companies
Who: Commonwealth companies that are required to prepare a sustainability report under section 292A of the Corporations Act 2001.
What: These companies report against the Australian Sustainability Reporting Standard AASB S2 Climate-related Disclosures.
When: Reporting follows a phased 3-year implementation depending on organisational size and other criteria. Reporting commenced from 1 January 2025 for Group 1 entities. Refer to ASIC’s For Preparers of Sustainability Reports to check the commencement date for each Group to begin reporting.
Stream 2: Commonwealth entities and smaller Commonwealth companies
Who: All non-corporate Commonwealth entities, corporate Commonwealth entities, and Commonwealth companies not covered by Stream 1, which are not in the carve out or out of scope are required to prepare a climate disclosure under section 516A of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). Entities are allocated into 3 Tranches.
What: Tranche 1 and 2 entities report against the Commonwealth Climate Disclosure Requirements. Tranche 3 entities report against the Commonwealth Climate Disclosure Simplified Requirements.
When: Reporting follows a phased implementation to build capability and improve how climate risks are understood and managed across the public sector. When reporting commences depends on the Tranche of the entity. Tranche 1 began reporting in FY 2024-25.
If you’re unsure which stream you belong to, refer to Foundations of Climate Disclosure.
Entities not subject to Commonwealth Climate Disclosure
The following government bodies are not subject to Commonwealth Climate Disclosure:
- Government bodies that are not Commonwealth entities or companies within the meaning of the Public Governance, Performance and Accountability Act 2013.
- These entities may still need to provide climate-related information to their parent entity to support aggregated disclosure (see Consolidated reporting).
- Commonwealth companies classified as Stream 1 under the Commonwealth Climate Disclosure policy
- Stream 2, Tranche 3 entities that meet both of the following criteria:
- fewer than 20 employees, and
- assessed as having no material exposure to climate risks and opportunities.
For more information on stream and tranche classification, contact climateaction@finance.gov.au.
What Tranche is my entity in?
Entities are Tranche 1, 2, or 3 based on type, size and organisational profile.
The following Commonwealth entities and companies are Tranche 1:
All Departments of State, all entities that are a 'controlling corporation' under the National Greenhouse and Energy Reporting Act 2007, all Specialist Investment Vehicles and the Future Fund Management Agency, and entities responsible for climate change or climate risk disclosure policy design or implementation, where not already covered by the following criteria.
Entities meeting at least 2 of the following 4 thresholds:
- Listed in Part 1 of the Climate Change (Consequential Amendments) Act 2022;
- Employ more than 500 employees;
- Hold total assets of $1 billion or more at the end of the financial year (including controlled entities);
- Have annual expenses of $500 million or more.
The following Commonwealth entities and companies are Tranche 2 if they meet at least 2 out of the following 4 thresholds:
- Listed in Part 1 of the Climate Change (Consequential Amendments) Act 2022.
- Employ over 250 employees;
- Hold total assets of $500 million or more at the end of the financial year (including controlled entities).
- Have annual expenses of $200 million or more.
The following Commonwealth entities and companies are Tranche 3. They follow the CCD Simplified Requirements.
- All remaining Commonwealth entities and Commonwealth companies, including Commonwealth companies which are not required to prepare a sustainability report under Section 292A of the Corporations Act 2001.
Tranche 3 Carve-out
Commonwealth entities and companies that meet the following criteria are only required to meet emissions reporting obligations under the Net Zero in Government Operations Strategy, and if applicable, obligations under the APS Net Zero by 2030 target.
- Classified as Tranche 3
- Have less than 20 employees
- Have been assessed to not have material exposure to climate risks and opportunities.
This information can also be found in the Commonwealth Climate Disclosure Policy
When does my entity begin reporting?
Reporting requirements increase progressively for each Tranche, until entities report against the full set of applicable requirements.
The table below shows when each Tranche begins climate disclosure reporting and the timing of applicable requirements.
Reporting start dates by Tranche
Unsure of what Tranche you belong to? Contact climateaction@finance.gov.au.
Tranche 1 and Tranche 2 rollout (3 years)
Commonwealth entities and companies in Tranche 1 and 2 transition to full climate disclosure reporting over a 3-year period:
Tranche 1
- Begins in FY2024–25 with Year 1 Requirements.
- Progresses to Year 2 Requirements in FY2025–26.
- Continues with Full (Year 3) Requirements from FY2026–27 onwards.
Tranche 2
- Begins in FY2025–26 with Year 1 Requirements.
- Progresses to Year 2 Requirements in FY2026–27.
- Continues with Full (Year 3) Requirements from FY2027–28 onwards.
Tranche 3 rollout (2 years)
Commonwealth entities and companies in Tranche 3 will report against the Simplified Requirements, which are tailored from the Full Requirements to reflect their reporting capability.
Tranche 3
- Begins in FY2026–27 with Year 1 Simplified Requirements.
- Progresses to and continues Full (Year 2) Simplified Requirements from FY2027–28 onwards.
For more information see Commonwealth Climate Disclosure Requirements.
